AQ_F_0100010_20210408_CEM_RptRvwLtr (4)

Etc STATE
ROY COOPER
Governor
DIONNE DELLFGATTI A
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
April 8, 2021
Mr. Kirk Yarbrough
Facility Manager
Stericycle, Inc.
Post Office Box 310
Haw River,North Carolina 27258-0310
SUBJECT: Review of 2020 CO/02 CEMS RATA
Stericycle, Inc. —Haw River Facility
Haw River, Alamance County,North Carolina
Air Permit No. 05896T25
Facility ID No. 0100010
Dear Mr. Yarbrough:
Thank you for the timely submittal of the subject report received, March 17, 2021, for the carbon
monoxide (CO)/oxygen(02) continuous emission monitoring systems (CEMS) operating at
Stericycle's Haw River facility. The Division of Air Quality(DAQ) has completed its review of
the relative accuracy test audit(RATA) and has the following comments:
1. The CO/02 analyzers monitoring incinerators ESO1 and ES02 were installed pursuant to 15A
NCAC 02D .1206 -Hospital, Medical, and Infectious Waste Incinerators and Air Permit No.
05896, Specific Condition 2.1.A.21 The CEMS is used to determine compliance with a CO
emission standard of 11 parts per million by volume (ppmv, 7% 02, 12-hour block average)
as listed in Table I to 40 CFR Part 60, Subpart Ce—Emission Guidelines and Compliance
Times for Hospital/Medical/Infectious Waste Incinerators [15A NCAC 02D .1206(c)(3)] and
Specific Condition 2.1.A.2.a.
2. Testing was conducted by TRC Environmental Corp. (TRC) on October 28, 2020. Reported
test results from the RATA indicated the CO and 02 analyzers appear to have met the relative
accuracy requirements set forth in 40 CFR Part 60, Appendix B, Performance Specification 3
(PS-3 for 02) and PS-4A (for CO) as summarized below.
Emission Source Parameter Relative Accuracy Specification
CO Primary 0.99 ppmv < 5 ppmv
ESO1 CO Backup 3.62% < 5% of emission standard*
F- 02 1.88% <20% of reference method
D EQ North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
NORTH CAROLINA _
oeparnmem of eammameami Quality /`� 919.707.8400

Mr. Kirk Yarbrough
April 8, 2021
Page 2
Emission Source Parameter Relative Accuracy Specification
CO Primary 1.71 ppmv < 5 ppmv
ES02 CO Backup 1.16 ppmv < 5 ppmv
OZ 0.84% <20% of reference method
*CO emission standard is 11 ppmvd at 7%Oz.
3. As indicated above, a RATA was also performed on the backup CO CEMS (Mfg/model:
Thermo Scientific/48i; Serial#: CM 09080036). Test results indicate the backup analyzer met
the requirements for relative accuracy as set forth in PS-4A. Should the backup CEMS be
pressed into service,please refer to our letter of December 12, 2012, for conditions of its use.
4. 40 CFR Part 60, Appendix F requires that quarterly audits must be conducted, with a RATA
being conducted at least once every four calendar quarters. The next RATA for ESO1 and
ES02 should be completed by December 31, 2021. Please ensure that quality
assurance/quality control (QA/QC)requirements are met and complied with at all times. In
addition,please notify this office at least 45 days prior to performing the annual RATA so
that arrangements can be made to observe the test.
If you should have any questions,please contact me at(919) 707-8493 or [e-mail].
Sincerely,
Drake, nvironme to ngineer
Division of Air Quality,NCDEQ
c: Kirk Yarbrough, Stericycle (e-copy)
Don Nuss, Stericycle (e-copy)
Ray Stewart, DAQ WSRO (e-copy)
Gary Saunders, DAQ SSCB (e-copy)
IBEAM Documents, 0100010 (e-copy)
Central File, Alamance County